Last Update: May 2025
Confidentiality and security are core values for Tus Media, SL, and for these values we are committed to ensuring user privacy at all times by limiting the collection of personal data to what is necessary and relevant to the purpose of processing.
In this privacy notice we provide you with information on:
This privacy policy is applicable to Website and App Users of our services.
Subsequently referred to as “Tus Media”, “we”, “our”, “us” or the “Data Controller”.
TUS MEDIA, SL (B-65640930)
Calle Pallars 3-5 Building B, 3-2, 08402 Granollers (Barcelona).
We process personal data in accordance with the use of the Tus Media Platform responsible for connecting teachers/ educational centers with students and vice versa. In the event that the teacher and/or educational center processes the student's Personal Data for activities other than those contemplated in the commercial relationship between Tus Media and the teacher and/or educational center, the teacher and/or educational center will be the sole controller of said personal data, and Tus Media will be exempt from any liability to such extent.
Tus Media, SL, by allocating its services to the same client profile (students and companies) as teachers and educational centers, will collaborate professionally with each other, which will require the exchange of personal data contained in their respective records of processing activities, such that both parties are joint owners of the aforementioned data, with teachers, educational centers and Tus Media acting as JOINT CONTROLLERS OF THE PROCESSING within the meaning provided under the General Data Protection Regulation (“GDPR”’).
Personal Data refers to any information or data that can directly or indirectly identify you. This includes information such as email address, postal address, zip code, telephone number, among others, and may vary depending on whether you are a student, teacher, or educational institution. It may also include unique numerical identifiers such as your computer's IP address, as well as information we obtain through cookies.
This Privacy Policy outlines the collection and use of Personal Data by Tus Media.
The user (“you”, “your”, “the student”, “teacher”, “company”, or “educational institution") hereby guarantees that the Personal Data provided is true and accurate and undertakes to notify us of any changes or modifications to the data. Any loss or damage caused to the Platform, the Data Controller, or any third party by providing erroneous, inaccurate, or incomplete information on the Platform forms shall be the User sole responsibility.
Tus Media aggregates information derived from your use of the Platform to implement improvements to the Platform's operation and provide you with recommendations that may be of interest to you.
We do not knowingly process the Personal Data of minors, Personal Data collected requires a minimum age of 14 years or, where applicable, the consent of the guardian.
The Personal Data we process may be necessary to carry out your requests and/or provide the services required. There are several legal bases relied on to process your personal data as provided under GDPR. In some instances we rely on Your consent as a User, on legal or contractual obligations, or on legitimate interest as Data Controller.
| Purpose of the Processing | Legal basis for processing | Personal Data Collected | Source |
|---|---|---|---|
| 1. managing registration and registration service on the Platform: To identify each user and provide you with access to the various features, products, and services available to you as a registered user. -To properly manage the services you subscribe to and provide you with the requested service. -Manage and monitor the contractual and pre-contractual relationship with you. -Facilitate contact with potential teachers and/or educational centers. -To enable contact with other users of the Platform through the instant messaging service. -To provide answers regarding the contracted services or services provided to the student, and respond to your requests. | The execution of the contractual relationship between the student and Tus Media. The legitimate interest of Tus Media. Your express consent. | Name and surname Email address Phone Province Student photograph City | "Students or Parents" Registration Form. "Contact without obligation" form. "Contact us" form. "Contact us" form, "Help" section. "Discover your ideal teacher" form. "Private Tutor Ad" form. "View phone number" form. |
| 2. Sending promotional commercial communications that include: To send commercial communications to inform you about our products and services, interviews, and opinions on current events in the education sector, including by electronic means. - To send personalized information and advertising, including by electronic means. -To send newsletters and promotions with advertising from other Tus Media sites (classgap.com, tusacademias.com, and tusclasesparticulares.com), as well as from educational centers and teachers. -To send alerts of new listings that match your search preferences, which you previously configured in "Alerts to my email." -To send offers and promotions from third parties in the education sector, including through electronic means. | Your express consent. The legitimate interest of Tus Media. | Name and surname Email address Phone Province City | “Students or Parents” Registration Form. “Looking for a Private Tutor” Form. “Contact without obligation” form. “Discover your ideal teacher” form. User Management Panel. |
| 3. Platform functionality, through technical and functional cookies: To ensure you receive reminders, technical recommendations, Platform service updates, security alerts, and support messages. -To Improve the services you may subscribe to by studying your student behavior and adapting them to your needs and preferences. -For the preparation of reports and statistics, in a dissociated manner. | Your express consent. The legitimate interest of Tus Media. | Data related to the use of the Platform. Registration Details. Pages in which you move within the Platform. Announcements in what has been entered. | Information collected through cookies and similar technologies during browsing on the Platform. |
| Purpose of processing | Legal basis of processing | Personal Data Collected | Source |
|---|---|---|---|
| 1. Managing registration and registration service on the Platform: To identify you as a user and provide you with access to the various features, products, and services available to you as a registered user. To properly manage the services you subscribe to and provide you with the requested service. Manage and monitor the contractual and pre-contractual relationship with you. Enable contact with potential students. To answer your questions regarding contracted services or services provided to teachers and educational centers, and to respond to your requests. If we receive your resume, your personal data may be added to our database for participation in our current or future selection processes. Post your ads. | The execution of the contractual relationship between the teacher and/or educational center and Tus Media. The legitimate interest of Tus Media. Your express consent. | Full name Email address Phone Province Locality Company name NIF/CIF/NIE Photograph Academic degrees and diplomas | "Advertise as a Teacher" form. “Register for Free” Form – “I am a Teacher”. “Register your Business” and “Academies and Centers” forms. “Job Offer for Teachers” Form. “Contact without Obligation” form. “Contact Us” form in the “Help” section. “Be a volunteer teacher” form. “Search Association” form. “Collaborate” form. “Start accepting students” form. |
| 2. Sending promotional commercial communications that include: To provide commercial communications about our products and services, interviews, and opinions on current events in the education sector, including by electronic means. - To send personalized information and advertising, including by electronic means. -To send newsletters and promotions with advertising from other Tus Media sites (classgap.com, tusacademias.com and tusclasesparticulares.com), including by electronic means. -To send alerts on new listings that match your search preferences, which you previously configured in "Alerts to my email." - To send you offers and promotions from third parties related to the education sector, including by electronic means. | Your express consent. The legitimate interest of Tus Media. | Full name Email address Phone Province Locality Name of the Company. NIF/CIF/NIE | "Advertise as a Teacher" form. “Register for Free” Form – “I am a Teacher”. “Register your Business” and “Academies and Centers” forms. “Job Offer for Teachers” Form. “Contact without Obligation” form. “Contact Us” form in the “Help” section. “Be a volunteer teacher” form. “Search Association” form. “Collaborate” form. “Start accepting students” form. "Alerts in my email." |
| 3. Platform functionality through technical and functional cookies: To ensure you receive reminders, technical recommendations, Platform service updates, security alerts, and support messages. - To Improve the services you may subscribe to by studying your student behavior and adapting them to your needs and preferences. -For the preparation of reports and statistics, in a dissociated manner. | Your express consent. The legitimate interest of Tus Media. | Data related to the use of the Platform. Registration Details. Pages in which you move within the Platform. Announcements in what has been entered. Duration of your visit to the Platform. | Information collected through cookies and similar technologies during browsing on the Platform. |
Nb: In instances where we process your personal data with your consent, you are at liberty to withdraw your consent at any given time by either refusing to give consent in the first place, withdrawing such given consent by unsubscribing from our newsletter for example, or deleting your profile picture. Notwithstanding, information processed prior to withdrawal of consent remains valid. In certain instances we may still process your personal data where we are relying on other legal basis for processing.
| Type of processing | Purpose of processing | Legal basis of processing | Source |
|---|---|---|---|
| Social Login | The Tus Media Platform also allows registration through synchronizing with third-party services (login with your Facebook account). | Consent | Link to third-party websites such as Facebook. |
| Instant messaging service | internal instant messaging system for direct communication between teachers and students participating in the Platform. Tus Media for the purposes of monitoring the service, controlling its quality, sending recommendations or personalized content, or even improvements within the system. | Consent (Also, through Terms and Conditions) | Directly from You. |
| Virtual Campus Service | Platform, through which the Tus Media user community, teachers, students, and educational centers exchange educational information and documents. Tus Media for the purposes of monitoring the service, controlling its quality, sending recommendations or personalized content, or even improvements within the system. | Consent (Also, through Terms and Conditions) | Directly from You. |
| Emails | To respond to your requests for information, address your requests, and respond to your questions or concerns. If we receive your CV, your personal and resume information may be added to our databases for participation in our current and future selection processes. | Consent Contract | Directly from You. |
| Payment | This includes the details of the card used to pay for the service, the cardholder's first and last name, credit or debit card number, credit or debit card expiration date, and the CCV. The major purpose is to manage payment for service. Tus Media has entrusted the credit or debit card payment system to two payment gateways, Redsys and Braintree. The bank details entered are encrypted and securely transmitted to the bank's servers and subsequently verified with the issuing bank to prevent potential fraud and abuse. | Contractual Obligation Legitimate Interest | Directly from You. |
Your Personal Data may be communicated to third parties in the following cases:
In some instances, for service efficiency, your Personal Data may be occasionally shared with service providers located in the United States of America or other countries or territories outside the European Economic Area. However, we ensure that any sharing of your personal information by us or the third parties with whom we share your personal information complies with the appropriate safeguards stipulated by respective Data Protection Laws.
We will only retain your Personal Data for as long as we need it for the purposes for which we process it or for as long as legally required.
We deploy artificial intelligence (“AI”) to improve our services which includes AI tutoring (“GoMigo”). Tutoring is done with the AI engaging the student on the TUS platform through interactive sessions using audio, voice, and text output for engagement.
The logic behind the development of GoMigo is to build a personalised learning path for users, help users master real life conversations with ease, provide instant feedback, continuous improvement, and track your progress with custom lessons to equip you with the right tools to accelerate your fluency in any language of your choice.
Users sign up to use GoMingo service with their email and passwords, after which you are asked questions relating to your learning goals, your current language proficiency, and selection of avatar for the AI Tutor. Users can then access the teaching platform where interaction with the AI begins with audio inputs then translated into text output (Speech-to-text-model) and vice versa.
User interaction may be used to curate more personalised content to their learning goals. The audio recordings are part of the personal data collected and are processed to the extent that we fulfill our contractual obligation to you in your learning path and our legitimate interest to ensure service quality, integrity and monitoring activities. We only retain such data to the extent that it is necessary for the purpose of processing.
It is important to note that our AI is developed implementing third-parties open source AI models (e.g., Open AI, Deepgram, and Elevenlabs). Thus, they may collect and store data as per their privacy policy and terms of service. We do not control and are not responsible for their data handling practices. We encourage users to review their privacy policies to understand their data practices.
The AI tutor may suggest a learning plan but you are at liberty to decide on a different learning plan. Further, we encourage users to limit the input of sensitive personal information in interaction with our AI model. Even though we integrate certain safeguards into the AI (“GoMigo”), Outputs may not be reviewed in advance and may be inaccurate, incomplete, misleading, offensive, objectionable, inappropriate, infringing, unsuitable, unlawful, unfit for particular purposes, or the same or similar to content generated for other users of the Services.
As users in addition to the rights stated in (8 below) you are entitled to request transparency and explainability of our AI services per the provisions of Art. 86 of the EU AI Act. Explainability here refers to the logic behind any automated-decision making or profiling performed by the AI Model. You may also request the intervention of a human in any decision making process involving AI where applicable. Further, you have a right to lodge a complaint with the relevant market surveillance authority.
Cookies are a category of online identifiers that function by storing small text files on your browser or device when you visit a website. They help enhance your experience by remembering user preferences, enabling certain functionalities, and collecting analytical data to improve service delivery.
Cookies may be classified into:
Tus Media uses the following types of cookies:
| Cookie Type | Functionality |
|---|---|
| Strictly necessary cookies (these cookies ensure platform services are available) | Authentication and login management. Session maintenance and platform security. Enabling user account access and preferences. |
| Functional Cookies (May also be added by third-party providers whose services we have added to our pages) | Remembering user preferences and settings. Supporting communication features such as instant messaging. Saving your progress within the virtual campus service. |
| Analytical/ Performance Cookies (could be used for reporting and statistical purposes) | These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our platform. They help us understand: Which pages are most and least popular. How users navigate the site. |
| Advertising and Targeting Cookies | Enable the display of personalized ads. Track the effectiveness of our marketing communications. |
We use cookies based on:
Your explicit consent, obtained through the cookie banner on our website.
Legitimate interest, where the cookie use is necessary for the operation and security of the platform.
You can withdraw your consent at any time by adjusting your browser settings or cookie preferences.
Tus Media works with third-party services such as:
These third parties may collect information about your use of our services and across other websites to build a profile of your interests.
We encourage you to review the privacy and cookie policies of these providers for more information on their data handling practices.
You can control and manage cookies in several ways:
Cookies may collect:
This information may be linked with your profile to personalize your experience on our platform.
Anyone may withdraw their consent at any time once it has been granted for the processing of their data. Under no circumstances does the withdrawal of this consent affect the execution of the subscription contract or any previously established relationships.
You may also exercise the following rights:
Where and how to request your rights: By writing to the Data Controller at their postal or electronic address (indicated in point 1), indicating the reference "Personal Data", specifying the right you wish to exercise and with respect to which personal data.
If you have a dispute with the company regarding the processing of your data, you can file a complaint with the Data Protection Agency (www.agpd.es).
The security of your personal data is of paramount importance to us and while we cannot “guarantee absolute security without breach”, we are constantly improving our security measures with respect to the processing of your personal data. Thus we implement technical and organizational measures to safeguard against unauthorized access, loss, destruction, alteration, or disclosure of your Personal data. More practically, we encourage the security of your personal data through using trusted cloud service providers who also value security of information, encryption measures, access controls, security assessments at necessary intervals. Further, we encourage that you keep your sign up information properly to prevent any unauthorised access, disclosure, or use.
In line with the principle of data accuracy, it is important you inform us whenever there has been any material change in your personal information so that we can update our records. Otherwise, we cannot be held responsible for its inaccuracy.
We are not responsible for the privacy policy regarding personal data you may provide to third parties through the links available on our Platform.
We may amend this Notice to reflect changes in the law, our companies, our Services, our data processing practices, or advances in technology. Our use of the personal data we collect may be subject to the Privacy Notice in effect at the time such personal information is used. Depending on the type of change, we may notify you of the change by posting on this website, update the “Last Updated” and take any other steps as may be required by law.
If you have any questions or concerns about how we process and use your personal data, or if you wish to exercise any of the rights described above, please contact privacidad@tusmedia.com.